- New VAT Treatment for Loans and Secondments: The Italian Chamber of Deputies approved an amendment to Law Decree No. 131/2024 that changes the VAT treatment of staff loans and secondment arrangements, making them subject to VAT.
- Effective Date: The amendment will apply to arrangements that become effective or are renewed on or after January 1, 2025.
- Reimbursement of Costs No Longer Exempt: Under the new amendment, loans of staff and secondments will be considered taxable supplies subject to VAT, even if the payment is merely a reimbursement of costs incurred.
- Alignment with EU Law: The amendment implements principles from the Court of Justice of the European Union’s San Domenico Vetraria ruling (C-94/19), aligning Italy’s domestic law with EU VAT rules.
- Impact on Existing Arrangements: Arrangements established before January 1, 2025, and not subject to final tax assessments will not be affected. Taxpayers should evaluate how this change may impact existing or soon-to-expire secondment arrangements.
Source Deloitte
See also
- Conversion of DL 131/2024: New VAT Regulation for Personnel Loans and Secondments
- C-94/19 (San Domenico Vetraria) – Judgment – Secondment of staff without markup is subject to VAT
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